Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
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The High Court dismissed the writ petitions challenging the validity of assessment u/s 153C and notices issued u/s 153B of the Income Tax Act. The court held that the starting point of limitation for passing the assessment order u/s 153B is the date when the seized books of account, documents, or assets were handed over to the Assessing Officer having jurisdiction over such person. The previous notices issued to the four transferor companies were void and irrelevant. The limitation period commenced from the date when the incriminating material was handed over to the jurisdictional Assessing Officer, even if time was consumed in centralizing the material. The court found no reason to interfere with the impugned orders and notices issued by the Department.
The High Court dismissed the writ petitions challenging the validity of assessment u/s 153C and notices issued u/s 153B of the Income Tax Act. The court held that the starting point of limitation for passing the assessment order u/s 153B is the date when the seized books of account, documents, or assets were handed over to the Assessing Officer having jurisdiction over such person. The previous notices issued to the four transferor companies were void and irrelevant. The limitation period commenced from the date when the incriminating material was handed over to the jurisdictional Assessing Officer, even if time was consumed in centralizing the material. The court found no reason to interfere with the impugned orders and notices issued by the Department.
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